In a March 20, 2018 letter to Secretary David Shulkin, M.D., HIMSS offered comments to the Department of Veterans Affairs (VA) in response to the Consent for Release of VA Medical Records Proposed Rule. In this letter, HIMSS leverages its members’ expertise in offering feedback on the proposed rule and looks forward to continuing to dialogue with the VA on how to facilitate the broader exchange of health information within the VA and across the community, as well as how our members can contribute to modernizing the healthcare our nation’s veterans receive.
HIMSS appreciates and supports the clarification that the Proposed Rule offers on changing the consent requirements around authorizing the VA to release a patient’s confidential VA medical record to a Health Information Exchange (HIE) community partner. HIMSS notes that the changes proposed will help facilitate better sharing of patient records with community healthcare providers, health plans, governmental agencies, and other entities participating in electronic HIEs.
HIMSS is also supportive of the two new criteria that the HIE community partners must provide written attestation that the patient has submitted legally sufficient consent to them, and that VA has the ability to retrieve or obtain this written consent within 10 business days of the HIE’s attestation. HIMSS appreciates that the VA has provided flexibility on whether the written consent has to be in an electronic format. They strongly urge VA to encourage its community partners to make the exchange process primarily electronic to minimize any administrative burden on the Department or its partners.